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ST-CS-4 | "The Company security awareness curriculum is developed and updated based on current threats, industry best practices, and significant information system changes." |
ST-CS-4 | "The prescribed timeline for remedial and disciplinary actions for non-complete New Hire Security Training is outlined in the Mandatory Training policy. Remedial actions pursuant to this policy include but is not limited to:" |
ST-CS-4 | "Information Spillage or Unauthorized Access Notification UAN" is included within Security Training."" |
ST-CS-4 | "In the event of an information system change to the FedRAMP boundary that triggers a Security Training content update, for example, the creation or significant update of Information Security policies or technologies, The Company will provide remedial Security Training to all employees and contractors. " |
ST-CS-4 | "The prescribed timeline for remedial and disciplinary actions for non-complete Annual Refresher Security Training is outlined in the Mandatory Training policy. Remedial actions pursuant to this policy include but is not limited to:" |
ST-CS-4 | "The Company documents and monitors individual information system security training activities including basic security awareness training and specific information system security training; and retains individual training records in accordance to The Company Records Retention Policy." |
ST-CS-5 | "The Company has role-based training that is provided annually." |
ST-CS-5 | "The Company documents and monitors individual information system security training activities including basic security awareness training and specific information system security training; and retains individual training records in accordance to The Company Records Retention Policy." |
ST-CS-6 | "The Company provides the Board of Directors annual Security Training that includes various information security topics." |
ST-CS-7 | "The Company provides employees (based on job role) who transfer into a role responsible for implementing, maintaining, or monitoring the Information Security Management Program security-specific training." |
ST-CS-7 | "Prior to a new employee (based on job role) starting their responsibilities for implementing, maintaining or monitoring the Information Security Management Program, security-specific training is completed." |
ST-CS-8 | "The Company security awareness curriculum is developed and updated based on current threats, industry best practices, and significant information system changes." |
ST-CS-8 | "Information Spillage or Unauthorized Access Notification UAN" is included within Security Training."" |
ST-CS-8 | "In the event of an information system change to the FedRAMP boundary that triggers a Security Training content update, for example, the creation or significant update of Information Security policies or technologies, The Company will provide remedial Security Training to all employees and contractors. " |
ST-CS-8 | "The Company conducts phishing simulations." |
TD-CS-1 | "Threat information is collected from open, human, commercial, and other sources, which are documented in the Threat Intelligence Playbook." |
TD-CS-1 | "Threat information is gathered to answer Priority Information Requirements as defined in the Cyber Intelligence Playbook." |
TD-CS-1 | "The Company Intelligence Analysts conduct research and analysis using a variety of research tools to enhance intelligence from the feeds." |
TD-CS-1 | "The Company Intelligence Analysts check applicability of threat information to The Company." |
TD-CS-2 | "The Company records threat intelligence that directly ties to Priority Intelligence Requirements in the Malware Information Sharing Platform (MISP) data warehouse." |
TD-CS-2 | "The Company publishes identified indicators to threat detection and prevention technologies, including but not limited to network-based IPS and DNS Sinkholes." |
TD-CS-2 | "Threat Intelligence information is provided regularly to the Cyber Operations team and include actionable threat information that is relevant to current cyber operations at The Company." |
TD-CS-2 | "Threat Intelligence reports are provided [INSERT TIME FRAME] to security teams and personnel, including the CISO, SVPs, BISOs, Security Advisements, and the Fraud Team. The reports include actionable threat information that is relevant to current cyber operations at The Company." |
TD-CS-3 | "The Company publishes identified indicators to threat detection and prevention technologies, including but not limited to network-based IPS and DNS Sinkholes." |
TD-CS-3 | "The Threat Intelligence team provides detection or prevention recommendations and other threat information to appropriate parties once actionable threat intelligence has been produced for threats relevant to The Company." |
TD-CS-4 | "The Insider Threat Program collects, analyzes, and correlates data; investigates identified suspicious activity; reports issues for appropriate remediation; assess likelihood of similar future exploitation by insider(s); and recommends solutions." |
VR-CS-1 | "The Company establishes a Vendor Relations Oversight Program including defining the roles and responsibilities involved in managing the regulatory compliance aspects of third party risk. The program is reviewed at least [INSERT TIME FRAME]." |
VR-CS-1 | "Third party security events are reported to the Chief Information Security Officer within [INSERT TIME FRAME] of receipt from the vendor." |
VR-CS-10 | "Periodic reassessments of vendors are performed." |
VR-CS-10 | "A material change occurs when responses to a New Engagement Questionnaire dictate a higher Inherent Risk Rating compared to previous engagements and the most recent assessment is outside the required cadence dictated by the higher Inherent Risk Rating." |
VR-CS-2 | "The Company conducts due diligence before selecting and entering into a contract with a third party. Extent of due diligence performed is determined based on risk categories:" |
VR-CS-2 | "Due diligence may need to be performed by one or more of the following teams:" |
VR-CS-3 | "The Company conducts due diligence before selecting and entering into a contract with a third party. Extent of due diligence performed is determined based on risk categories:" |
VR-CS-4 | "Prior to entering into a relationship with a vendor, The Company requires a written contract. Based on the service provided and data accessed, the contract may include one or more of the following:" |
VR-CS-4 | "The vvendor agrees to adhere to The Company's External Party Security Standard and other relevant external security standards, as appropriate." |
VR-CS-4 | "Contract language that deviates from standard The Company terms and conditions is reviewed by The Company Legal Department and, as applicable, Security prior to contract execution." |
VR-CS-5 | "The Company maintains an inventory of The Company approved third parties. Processes to address completeness and accuracy of the inventory of the vendor are implemented:" |
VR-CS-6 | "The Company takes a risk-based approach in conducting client due diligence, during the credentialing process, based upon client industry, products consumed, as well as any applicable judicial or regulatory requirements." |
VR-CS-6 | "The Company follows the general credentialing process outlined below to address security risks:" |
VR-CS-6 | "The Company's Credentialing and Account Services Team defines, documents and maintains an approved Credentialing process, with supporting documentation, which outlines the requirements to validate the legitimacy of The Company clients and the clients' permissible purpose to access The Company credit data or Sensitive Information under the Fair Credit Reporting Act (FCRA)." |
VR-CS-6 | "The Company conducts a review and makes updates to the credentialing process and supporting documentation as deemed necessary, at least on an [INSERT TIME FRAME] basis." |
VR-CS-6 | "The Company takes a risk-based approach to the periodic re-credentialing of The Company clients with access to The Company Credit Data or Sensitive Information. The re-credentialing is performed to validate the continued client legitimacy and Permissible Purpose, based upon Client Industry, products consumed, as well as any applicable judicial or regulatory requirements." |
VR-CS-6 | "The Company follows the general re-credentialing process outlined below to address security risks:" |
VR-CS-7 | "The Company takes a risk-based approach to the periodic re-credentialing of The Company clients with access to The Company Credit Data or Sensitive Information. The re-credentialing is performed to validate the continued client legitimacy and Permissible Purpose, based upon Client Industry, products consumed, as well as any applicable judicial or regulatory requirements." |
VR-CS-7 | "The Company follows the general re-credentialing process outlined below to address security risks:" |
VR-CS-8 | "The Company provides training to relevant employees on the Credentialing process on at least an annual basis, or as needed, as changes are made to the process or the supporting Credentialing process documentation." |
VR-CS-9 | "An approved third party risk assessment methodology is defined and implemented." |
VR-CS-9 | "The Company follows the Security Risk Assessment process outlined below to address cybersecurity risks:" |
VR-CS-9 | "The Company takes a risk-based approach in assessing third party engagements and prioritizes third parties according to the Asset Risk Assessment Methodology. The criteria used to calculate the inherent risk rating (IRR) and prioritize third party engagements are based on the following data attributes:" |
VR-CS-9 | "The Inherent Risk Rating (IRR) for third party engagements are defined below:" |
VR-CS-9 | "The effectiveness of security controls within a vendors's environments are reviewed [INSERT TIME FRAME]." |
VR-CS-9 | "The Company performs assessments of third parties in alignment with program requirements." |
VR-CS-9 | "Periodic reassessments of vendors are performed." |
VM-CS-1 | "The Company receives vulnerability information from multiple sources." |
VM-CS-1 | "The Threat and Vulnerability Management teams review, analyze, and report on vulnerabilities newly identified by its vulnerability scanning vendor [INSERT TIME FRAME]." |
VM-CS-1 | "The Threat Intelligence Team reviews and analyzes intelligence reports on vulnerabilities for relevant software and notifies the Threat and Vulnerability Management team of any relevant vulnerabilities." |
VM-CS-1 | "The Company analyzes vulnerability information to determine the following:" |
VM-CS-1 | "For The Company systems deployed in its FedRAMP boundaries, The Company analyzes vulnerability information using procedures and/or checklists to determine the following: Applicability to The Company systems and applications (i.e., is the affected technology in-use at The Company) Potential impact to The Company systems, applications, and data (i.e., if exploitation of this vulnerability could be a material risk to The Company)" |
VM-CS-10 | "Application and System Owners commence remediation planning for all critical vulnerabilities within [INSERT TIME FRAME] of identification." |
VM-CS-10 | "Application and System Owners mitigate any critical vulnerability within [INSERT TIME FRAME] of vulnerability identification." |
VM-CS-10 | "Cyber Operations declares a Zero Day Alert and notifies all Application Owners and Patch Champions when a Critical vulnerability has been identified that meets the following criteria:" |
VM-CS-10 | "Cyber Operations includes the following information in each Zero Day alert:" |
VM-CS-11 | "If a security event occurs due to a vulnerability exploitation, system and application owners are responsible for completion of remediation of the vulnerability within [INSERT TIME FRAME] of notification of such event. If that vulnerability cannot be remediated within [INSERT TIME FRAME] of its identification, then compensating controls are identified and implemented or the system is decommissioned within [INSERT TIME FRAME] of the identification of the vulnerability. " |
VM-CS-11 | "Application and System owners remediate or mitigate vulnerabilities within the following targeted timeframes:" |
VM-CS-11 | "Application and System Owners commence remediation planning for all critical vulnerabilities within [INSERT TIME FRAME] of identification." |
VM-CS-11 | "Application and System Owners mitigate any critical vulnerability within [INSERT TIME FRAME] of vulnerability identification." |
VM-CS-11 | "Application and System Owners review scan results to verify that the vulnerability has been remediated prior to reporting that the vulnerability has been remediated." |
VM-CS-11 | "If automated scanning cannot verify remediation, manual testing is performed to validate that the vulnerability has been remediated and the vulnerability status must be manually updated in the vulnerability management system to reflect the status of the vulnerability." |
VM-CS-11 | "If a security event occurs due to a vulnerability exploitation, system and application owners are responsible for completion of remediation of the vulnerability within [INSERT TIME FRAME] of notification of such event." |
VM-CS-2 | "The Company has a vulnerability disclosure program for external sources to report identified vulnerabilities." |
VM-CS-2 | "The Company has a process to allow internal sources to report vulnerabilities using phone and email communications channels." |
VM-CS-3 | "The Company performs automated vulnerability scans of systems at the following frequency:" |
VM-CS-3 | "Automated vulnerability scans are configured to enumerate the following for each discovered system: Operating system, Hostname, IP address, Open ports, Listening services, and Operating system and software vulnerabilities" |
VM-CS-3 | "For The Company systems deployed in its FedRAMP boundaries, The Company performs procedures to identify and ensure all systems within the FedRAMP boundary are being scanned for vulnerabilities. " |
VM-CS-3 | "Automated vulnerability scanners are configured to update signatures throughout the day." |
VM-CS-4 | "The Company performs automated vulnerability scans of systems at the following frequency:" |
VM-CS-4 | "Automated vulnerability scans are configured to enumerate the following for each discovered system: Operating system, Hostname, IP address, Open ports, Listening services, Operating system and software vulnerabilities" |
VM-CS-4 | "Automated vulnerability scanners are configured to update signatures throughout the day." |
VM-CS-4 | "For The Company systems deployed in its FedRAMP boundaries, The Company performs procedures to identify and ensure all systems within the FedRAMP boundary are being scanned for vulnerabilities. " |
VM-CS-4 | "For The Company systems deployed in its FedRAMP boundaries, The Company performs authenticated scans of Operating Systems, databases, and web applications." |
VM-CS-5 | "The Company has implemented a risk-based approach to perform penetration testing based on compliance and regulatory requirements." |
VM-CS-5 | "The Company performs penetration testing according to OWASP and NIST methodologies and standards." |
VM-CS-6 | "The Company uses an industry-standard framework to assign a risk rating to vulnerabilities identified through automated scanning." |
VM-CS-6 | "The Company uses the following CVSS Version 3 guidance to assign a risk rating to vulnerabilities that were not identified by an automated tool (e.g., findings identified by a penetration test): " |
VM-CS-6 | "Penetration Testers use CVSS to assign risk criticality to manually identified vulnerabilities." |
VM-CS-6 | "The Vulnerability Management team uses CVSS to assign risk criticalities to manually identified vulnerabilities reported through internal and external reporting processes." |
VM-CS-7 | "Cyber Operations ensures that Vulnerability scan reports are communicated to designated patch champions." |
VM-CS-7 | "Cyber Operations provides patch champions with vulnerability scan reports in accordance with established scan schedules." |
VM-CS-7 | "The Patch Management Group has access to repositories containing documented vulnerabilities." |
VM-CS-7 | "If any vulnerability with a CVSS 3 score greater than a 7.0 is actively present within the FedRAMP authorization boundary, the FedRAMP SOC will be notified with all vulnerability details in order to investigate whether the vulnerability has been previously exploited." |
VM-CS-8 | "Application and System owners remediate or mitigate vulnerabilities within the following targeted timeframes:" |
VM-CS-8 | "The Company documents vulnerabilities in a system that conforms to The Company Records Retention Policy." |
VM-CS-8 | "Cyber Operations reports identified vulnerabilities to the responsible Business Unit until they have been remediated." |
VM-CS-8 | "Cyber Operations documents the following attributes for each identified vulnerability:" |
VM-CS-8 | "The Company employs automated mechanisms to compare the results of vulnerability scans for the FedRAMP boundary over time to determine trends in information system vulnerabilities." |
AC-CS-1 | "For The Company systems deployed in its FedRAMP boundaries, User identities for Employees, Contingent workers, and Foreign Nationals identify them as such." |
VM-CS-9 | "Vulnerabilities identified by automated scanning are rescanned upon report of remediation or upon next regularly scheduled automated scan to confirm the vulnerability has been remediated." |
VM-CS-9 | "Application and System Owners review scan results to verify that the vulnerability has been remediated prior to reporting that the vulnerability has been remediated." |
VM-CS-9 | "If automated scanning cannot verify remediation, manual testing is performed to validate that the vulnerability has been remediated and the vulnerability status must be manually updated in the vulnerability management system to reflect the status of the vulnerability." |
RM-CS-10 | "The Company designs, implements, maintains, and documents safeguards that mitigate the material internal and external risks The Company identifies to the privacy of personal data." |